Text

Application for Amend to License NPF-43,incorporating Change to Tech Specs 3/4.6.5.1 Re Secondary Containment Integrity & Definition 1.36
	ML20245L609
Person / Time
Site:	Fermi
Issue date:	04/21/1989
From:	Sylvia B; DETROIT EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245L613	List: ML20245L652; NRC-89-0093, Application for Amend to License NPF-43,incorporating Change to Tech Specs 3/4.6.5.1 Re Secondary Containment Integrity & Definition 1.36;
References
	CON-NRC-89-0093, CON-NRC-89-93 NUDOCS 8905080085
	Download: ML20245L609 (14)
	v • d • e

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o B. Rolph Sylvia Senior Vice President Detro? _. c ,, ,e ,

Edison =m"-

i April 21,1989 NRC-89-0093 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Information Notice No. 89-26,

" Instrument Air Supply to Safety-Related Equipment", dated March 7,1989

3) Transmittal of Licensee Event Report ,

89-005-01, dated April 10, 1989 l

Subject:

Proposed Technical Specification Change (License Amandment) - SIC,OhDARY CONTAIN4ENT INTEGRITY (DEFINITTON 1 36 and Technical Specification 3/4.6.5.1)

Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes to Technical Specification 3/4.6.5.1 SECONDARY CONTAINMENT INTFGRITY and DEFINITION 1.36.

l The Reactor Building, in conjunction with the functions performed by the Reactor Building Heating and Vex 11ation Systems and the Stan1by Gas Treatment System, constitutes Fermi 2's secondary containment.

The proposed changes address a design modification to Reactor Building's railroad bay air lock doors. This design change is a result of a concern with the reliability of secondary containment integrity barriers that depend on non-safety related air supply systems (see Reference 2).

As discussed in Reference 3, Detroit Edison has identified that both Reactor Building railroad bay air lock door seals are currently supported by a non-safety related air supply system. A foam seal has been installed and tested which maintains SECONDARY CONTAIWENT INTB3RITY of the subject air lock as a short term measure.

Additionally, sand bags have been staged to provide the required flood l protection normally provided by the inflated railroad bay air lock door seals.

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. April 21, 1989 NRC-89-0093 Page 2 This short term modification is not practical for normal ingress and egress through the Reactor Building's railroad bay air lock.

Therefore, we are requesting the approval of this proposed amendment to be effectiva as soon as possible so that a permanent improvement ?

can be placed in service following installation. This change is needed before June 1,1989 to ansist in the movement and storage of new fuel that is scheduled to be delivered to Fermi 2 during the first week of June, 1989.

The permanent design modification, as described in the attached enclosure, is currently scheduled to be installed and fully operational by the time the new fuel arrivea on site.

For your convenience attached to the enclosure is a copy of the existing Technical Specifications for Secondary Containment, the proposed Technical Specifications and diagrams of the proposed modification.

l Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specification change and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

Sincerely,

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Enclosure cc: A. B. Davis R. C. Knop W. G. Rogers J. F. Stang Supervisor, Advanced Planning and Review Section Michigan Public Service Commission f

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USNBC April'21,- 1989

NRC-89-0093 Page 3 I, B. . RALPH SYLVIA, do hereby affirm. that the foregoing statements are based on facts and circumstances which are true and mcurate to the best of my knowledge and belief.

I d$dal B'. = #4 Syt w b/

Senior Vice President Cn this O day of M , 1989, before me personally appeared B. Ralph Sylvik being first duly sworn and says that he executed the foregoing as his free act and deed.

dl. 0 W Notary Public ROSAUE A ARMEITA l Notary Pub!!c. Monroe County,MI MyCommissionExpiros.icn.11.1992 l

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Enclosure to

, NRC-89-0093 4 Page 1 j 1

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BACKGROUND / DISCUSSION l

The purpose of this submittal is to propose Technical Specification i changes which are more commensurate with a design change to the l railroad bay air lock doors. This design change is a result of 1 industry concerns (Reference 2) with the reliability of secondary i containment integrity barriers that depend on non-safety related air i supply systems to perform their containment function. The Reactor Building, in conjunction with the functions' performed by the Reactor )

Building Heating and Ventilation System and the Standby Gas Treatment l System, constitutes Fermi 2's secondary containment. Fermi 2's secondary containment boundary provides an essentially leak-tight barrier against uncontrolled flow of air into or out of the Reactor )

Building. The secondary containment is normally maintained at a I pressure of .125 inches H 2O differential pressure and .25 inches H 2 O differential pressure, post accident. This prevents the dissipation of contaminated air directly to the environment and limits the release of radioactivity. In order to allow access into and out of the Reactor Building and maintain the secondary containment l negative pressure differential, personnel and equipment air locks, and a railroad bay air lock are provided. All of these access paths have double doors in order to maintain secondary containment integrity during Reactor Building ingress and egress. (One door in each air lock is always maintained closed). All of these air locks have

" passive" seals on each door, except for the railroad bay air lock.

The railroad bay air lock doors perform their secondary containment (essentially air-tight) and flood protection (essentially ater-tight) functions by the usc of inflatable seals located in the owcr perimeter of the doors. These seals, QA Level 1, are currently supplied from an " active" non-safety related air supply which is not normally powered from an emergency power supply.

Because of the railroad bay air lock door seals' air supply j inadequacies, Detroit Edison has performed secondary containment l integrity tests to determine if Technical Specification required negative pressures could be maintained without the seals inflated.

These terts determined that secondary containment pressure could not i be maintained within Technical Specification limits without at least a single air lock door seal inflated. A short term modification has !

been implemented which installed a foam seal between the railroad bay outer door and the door's weather stripping. Subsequent testing has confirmed that this modification allows secondary containment to be .

maintai_ed within Technical Specification limits with the seals !

deflated. However, this modification is not desirable as a permaner'. )

design because testing is required after each opening of the door, I l

installation and removal of the foam seal is very time consuming and j the modification is not water-tight. (Please note that in accordance j 1

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Enclosure to

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Page 2 with the UFSAR, the lake water level rises for several hours prior to exceeding the site grade level. This will allow time for the operations staff to take actions such as installing sand bags to ,

provide flood protection in-lieu of having the railroad bay air lock door seals inflated. As a precautionary measure in the interim, sand bags have been staged.)

A design modification is being prepared (see Attached Figures) that will-provide the railroad bay door seals with air from a qualified safety related source. The inner door seal will be supplied from Division I of the Non-Interruptible Air Supply (NIAS) System and the outer door seal will be supplied from Division II of the NIAS System.

The NIAS System consists of two 100 percent capacity air compressors and distribution systems (Division I and Division II). The NIAS System is safety related and seismically supported (Category I). The NIAS System's air compressors are automatically loaded on to the emergency diesel generators (EDGs) upon the loss of offsite power to the air compressor (s) electrical bus (es). The design modification-analysis has determined that sufficient capacity exists in the NIAS System to supply the railroad bay door seals concurrent with the

' system's existing loads. Air supply lines from the associated NIAS ;

Division to each railroad bay air lock door seal will be seismically qualified and will be provided with a restrictive orifice and !

individual receiver tank. The restrictive orifice will limit NIAS leakage such that a rupture of a door seal will not degrade the function of other equipment which depend on the NIAS System. The individual receiver tanks on each doov's air supply line will provide a reserve volume such that the existing NIAS System's Divisional receiver tanks design basis is not invalidated. The existing and new receiver tanks are designed to provide a 10_ minute reserve capacity independent of the NIAS Air Compressor (s) input even though the NIAS Compressors are supplied by emergency power.within approximately 48 seconds after loosing offsite power. The individual receiver tank on each door seal's air supply line will also assist in normal inflation of the seal.

Control room alarms for low railroad bay air lock door seal pressure will be installed for each door. This will allow continuous monitoring by control room personnel of the railroad bay air lock door's SECONDARY CONTAINMENT INTEGRITY. The door seals' pressure provides an excellent indication of the railroad bay air lock's SECONDARY CONTAINMENT INTEGRITY because the seals are the only components on the doors which rely on " active" equipment for their safety function OPERABILITY. The existing automatic seal inflation circuitry will be removed because it is not safety related and its failure could lead to an unintentional seal deflation. The design

Enclosure.to

, NRC-89-0093 "LPage 3 t-modification has provisions for manually inflating and deflating each door seal individually.

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Implementation of the proposed modification necessitates additional controls to ensure that both railroad bay air lock doors remain closed and sealed because of the vulnerability of the system to'a single active failure if only one-door is normally required to be closed and sealed. The existing secondary containment Technical Specification 4.6.5 1.b.1 only requires one railroad bay access door to be. closed. . ,

In order to address the proposed modification, the following Technical .I Specification' changes are proposed (see attached proposed Technical Specifications): 'l 1

1) The existing DEFINITION of SECONDARY CONTAINMENT INTEGRITY, '.36, does not specifically address the railroad bay air lock. The proposed changes add a clarification to item "d" to prevent a-misinterpretation that this item applies to the railroad bay doors. As specified in proposed item "g" both railroad bay access doors are required b be OPERABLE and closed because of the vulnerability of the system to a single active failure if only one door is norutally required closed. 1

2) The existing Limiting Condition for Operation (LCO) in ,,

. conjunction with the proposed SECONDARY CONTAINMENT INTEGRITY j DEFINITION has no provisions for normal ingress and egress '

l through the railroad bay air lock or for routine testing of doors alarm / indication instrumentation if both doors are required closed. Thus, the proposed footnote will temporarily suspend the proposed "two door closed and OPERABLE" requirement for ingress and egress through the railroad bay air lock and for routine testing of the doors alarm / indication instrumentation. The

' temporary suspension of the LCO will only be allowed for four hours provided one of the.two doors is open and the other a:,r lock door is OPERABLE and closed. The existing Technical x Specification allows four hours to recover from a complete loss of SECONDARY CONTAINMENT. INTEGRITY before a reactor shut down is required. The footnote's 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period.is needed to allow sufficient time for transfer of new fuel. The railroad bay air lock is needed to temporar*1y store the empty new fuel shipping

' crates in order to off-load a complete shipment of new fuel.

Closing and opening the inner air lock dear after placement of.

each new fuel shipping crate in the air lock is unnecessary, because of the short period of time one of the two doors will be open and the infrequent number of shipnents (approximately eight ;

per 18 months). Additionally, both of the footnote's time limits are justified based on the low probability of a single failure on the closed door, the low frequency of a door being open and the

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Enclosure to NRC-89-0093 Page'4 low probability of an accident requiring SECONDARY CONTAINMENT.

INTEGRITY. .

3). The existing LCO, in conjunction with the proposed two door closed and OPERABLE requirement, has no realistic provisions for a single inoperable railroad bay air lock door. The existing ACTION "a'! is based on the complete loss of one or more secondary containment penetrations and/or barriers, or the loss of secondary containment pressure. The proposed ACTION "b" provides requirements for the situation where only one railroad bay air lock door is inoperable; in this case, the railroad bay secondary containment penetration is still isolated by.the other railroad bay door.--The existing ACTIONS are based upon situations where SECONDARY CONTAINMENT INTEGRITY is completely compromised. The 7 day out of service time limit on proposed ACTION "b.1" is

-consistent with Technical Specification 3 6.5 3, Standby Gas Treatment System (SGTS) and the General Electric Standard Technical Specification (GESTS) f)r the SGTS.. The-SGTS configuration and function, and the. proposed modification configuration are similar in that.5oth systems support SECONDARY CONTAINMENT. INTEGRITY, both systems have 100% redundant capabilities and both systems are safety related. Proposed ACTION "b.2" is consistent with existing ACTION "b" and the GESTS for SECONDARY CONTAINMENT INTEGRITY.

4) .The existing.31-day surveillance requirement 4.6.5.1.b.1 only 'I requires verification of one railroad bay air. lock door. The proposed change to this surveillance requirement.will require that at least once per 31 days both railroad bay air lock. doors are verified closed and sealed.

The proposed changes enhance the overall safety of the system because:

o Two railroad bay air lock doors will be required closed during normal operation as opposed to one railroad bay door which is currently required by the existing Technical Specifications.

This will effectively increase the capability and reliability of !

SECONDARY CONTAINMENT INTEGRITY compared to the existing configuration.

o The design modification will supply the safety related railroad bay air lock door seals with safety related air from the existing fully qualified and redundant NIAS System. The design modification analysis has evaluated the NIAS System and determined that it is capable of handling the increase railroad bay door seal (s) loads. Additionally, the design modification will include provision (s) (restrictive orifices and . receiver i

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Page 5 tanks) such that a rupture of railroad bay air lock seals will not affect the function of other equipment which depend on the NIAS System.

o Control room alarms for low railroad bay air lock door seal i pressure will be installed for each door. This will allow-continuous monitoring by control rcom personnel of the railroad bay air lock door's SECONDARY CONTAINMENT INTEGRITY. The door I

seal's pressure provides an excellent indication of the railroad bay air lock's SECONDARY CONTAINMENT INTEGRITY because the seals are the only components on the doors which rely on " active" equipment for their safety function operability, o The proposed ACTIONS are consistent with accepted industry standards for related equipment of similar redundancy and safety classification which are also required to support SECONDARY CONTAINMENT INTEGRITY.

I o The proposed footnote, which will allow opening of one of the two air lock bay doors, is only applicable if the other air lock door is OPERABLE and closed. Both footnotes time limits are based on J engineering judgement considering the low probability of a single failure on the closed door, the low frequency of a door being open and the low probability of an accident requiring SECONDARY CONTAINMENT INTEGRITY. Additionally, if within the 4 or 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period, allowed for one railroad bay air lock door to be open, the closed door becomes inoperable because of. a loss of seal pressure (the only active component dependent on an active system) control room personnel would immediately receive the low seal pressure alarm.

SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination i that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operaticn in accordance with the proposed amendment ,

would not: 1) involve a significant increase in the probability or l l

consequenc . of an accident previously evaluated, or 2) create the l' possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a i L margin of safety.

1) The proposed changes do not involve a significant increase in the ,

probability or consequences of an accident previously evaluated (

because the capability and reliability of SECONDARY CONTAINMENT j INTEGRITY has been increased. Two railroad bay air lock doors l

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Enclosure to NRC-89-0093 Page 6 will be required to be closed and sealed during normal operation as opposed to one railroad bay air lock door which is currently required by the existing Technical specifications. The subject ,

door's seals will be supplied from a safety related, seismically qualified and fully redundant non-interruptible air supply system. The existing air supply for these door seals is not safety related, not seismically qualified and not redundant. The proposed system will be single failure proof provided both railroad bay air lock doors are closed. l The proposal includes ACTIONS for one of the two railroad bay air lock doors inoperable; in this case, the railroad bay secondary <

containment penetration is still isolated by the other railroad t bay air lock door. The existing ACTIONS are based upon situations where SECONDARY CONTAINMENT INTEGRITY is completely compromised. The 7 day out-of-service time limit on propose

ACTION "b.1." is cr.nsistent with Technical Specification 3 6 Standby Gas Treatment System (SGTS) and the General Electric Standard Technical Specification (GESTS) for the SGTS. The SGTS configuration and function, and the proposed modification configuration are similar in that both systems support SECONDARY CONTAINMENT INTEGRITY, both systems have 100% redundant capabilities and both systems are safety related. Proposed >

ACTION "b.2" is consistent with existing ACTION "b" and the GESTS for SECONDARY CONTAINMENT INTEGRITY.

l The proposed footnote that will allow ingress and egress through !

one railroad bay air lock door or routine testing of the doors' alarm / indication instrumentation is based on engineering judgement considering the low probability of a single failure on the closed door, the frequency of a door being open and the low probability of an accident requiring SECONDARY CONTAINMENT INTEGRITY. If within the four or 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period allowed for one railroad bay air lock door to be open, the closed door becomes inoperable because of a loss of door seal pressure (the only component dependent on an active system) control room '

personnel would immediately receive the low seal pressure alarm.

Secondary containment functionality could then be restored by closing '.he door that was open. The existing Technical Specifiv tion allows four hours to recover from a complete loss of SECONDARY CONTAINMENT INTEGRITY before a reactor shut down is required. The footnote's 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period is only applicable when fuel is received onsite which is only expected to consist of approximately eight shipments in 18 months. The existing 31-day surveillance requirement, 4.6.t.1.b.1, has been modified so that both railroad bay doors are required to be verified closed every 31-days. Therefore, the proposed changes do not significantly i

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Enclosure to NRC-89-0093 Page 7 increase the probability or consequences of an accident previously evaluated because two railroad bay doors are required OPERABLE and closed and the door seals will be supplied by a safety related and redundant air system. The proposed ACTIONS are consistent with accepted industry standards for related systems of similar i+3undancy and safety classification which are also required to support SECONDARY CONTAINMENT INTEGRITY.

2) The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because the capabilities of the railroad bay air lock door system have been increased and the railroad bay air lock door seals will i be supplied with safety related air from the existing NIAS l System. The NIAS System is safety related, fully redundant and ]

seismically supported. The NIAS System's air compressors are I automatically loaded on to the EDGs upon the loss of offsite power to the air compressor (s) electrical bus (es). An engineering evaluation has determined that sufficient capacity exists in the NIAS System to supply the railroad bay door seals concurrent with the system's existing loads. The design i modification will provide restrictive orifices and receiver tanks such that a rupture of the railroad bay air lock seals will not affect the function of other equipment which depend on the NI AS i System. Control room alarms for low railroad bay air lock door seal pressure will be installed for each door. This will allow continuous monitoring by control room personnel of the railroad bay air lock door's SECONDARY CONTAINMENT INTEGRITY. The door seal's pressure provides an excellent indication of the railroad bay air lock's SECONDARY CONTAINMENT INTEGRITY because the seals are the only active component on the doors which rely on active equipment for their OPERABILITY. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because the railroad bay air lock door seals will be supplied from a fully qualified air system and the new design will enhance the system's capability and not degrade any related systems or equipment functions.

3) The proposed changes do not involve a significant reduction in the margin of safety because the previously stated design modifications and proposed Technical Specifications increase the capability and reliability of SECONDARY CONTAINMENT INTEGRITY compared to the existing configuration. The design modification and proposed Technical Specification changes effectively add an

" additional barrier" between secondary containment and the environment for the railroad bay air lock. Additionally, the

e n i Enclosure to 1 NRC-89-0093 Page 8 only active component utilized for these redundant barriers will be supported from a fully qualified safety related system.

Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.~

i ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification change against the criteria of 10CFR51.22 for e' environmental considerations. The proposed ahange.does not involve a significant hazards consideration,-nor .oiricantly change the types or significantly increase the ce unts of effluents that may be released offsite, nor significantly increase individual or cumulative . ;

occupational radiation exposures. Based on the foregoing, Detroit l Edison concludes that the proposed Technical Specification meets the !

criteria given in 10CFR51.22(c)(9) for a categorical exclusion from j the requirements for an Environmental Impact Statement.

I CONCLUSION Based on the evaluation above: 1) there is reasonable assurance that !

the health and safety of the public will not be endangered by operation in the proposed manner, and 2) such activities will be . .

conducted in compliance with the Commission's regulations and proposed ,

amendments will not be inimical to the common defense and security or !

to the health and safety of the public.

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EXISTING SECONDARY CONTAINMENT TECHNICAL i

j SPECIFICATIONS l

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, q DEFINITI'ONS l

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REACTOR PROTECTION SYSTEM RESPONSE TIME ..

1.33 REACTOR PROTECTION SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The essponse time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured. )

REPORTABLE EVENT j 1.34 A' REPORTABLE EVENT shall be any of those conditions specified in Sec- 1 I tion 50.73 to 10 CFR Part 50. l1 R0D DENSITY 1.35 ROD DENSITY shall be the number of control rod notches inserted as a fraction of the total number of control rod notches. All rods fully inserted is equivalent to 100% ROD DENSITY.

4 SECONDARY CONTAINMENT INTEGRITY 1.36 SECONDARY CONTAINMENT INTEGRITY shall exist when: l

a. All secondary containment penetrations required to be closed during accident conditions are either:

1. Capable of being closed by an OPERABLE secondary containment

, automatic isolation system, or

2. Closed by at least one manual valve, blind flange, or deactivated automatic damper secured in its closed position, except as ]

provided in Table 3.6.5.2-3 of Specification 3.6.5.2.

b. All secondary containment hatches and blowout panels are closed !

and sealed.

c. The standby gas treatment system is in compliance with the require-ments of Specification 3.6.5.3.

d. At least one door in each access to the secondary containment is !

closed.

e. The sealing mechanism associated with each secondary containment -

penetration, e.g., welds, bellows or 0-rings, is OPERABLE.

f. The pressure within the secondary containment is less than or equal j to the value required by Specification 4.6.5.1.a. l

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SHUTDOWN MARGIN ]

1.37 SHUTOOWN MARGIN shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming all control rods are fully inserted except for the single control rod of highest reactivity worth which is assumed to be fully withdrawn and the reactor is in the shutdown condition; cold, i.e., 68'F; and xenon free.

SITE BOUNDARY 1.38 The SITE BOUNDARY shall be that line'beyond which the land is neither owned, nor leased, nor otherwise controlled, by the. licensee. , ]

FERMI - UNIT 2 1-6 l 4

Extslm_L_

CONTAINMENT SYSTEMS

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3/4.6.5 SECONDARY CONTAINMENT SECONDARY CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.5.1 SECONDARY CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, and *.

ACTION:

Without SECONDARY CONTAINMENT INTEGRITY:

a. In OPERATIONAL CONDITION 1, 2, or 3, restore SECONDARY CONTAINMENT INTEGRITY within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. In Operational Condition

suspend handling of irradiated fuel in the secondary containment, CORE ALTERATIONS and operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.6.5.1, SECONDARY CONTAINMENT INTEGRITY shall be demonstrated by:

a. Verifying at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the vacuum within the secondary containment is greater than or equal to 0.125 inch of vacuum water gauge.

b. Verifying at least once per 31 days that:

1. All secondary containment equipment hatches and pressure relief doors are closed and sealed and one railroad bay access door is closed.

2. At least one door in each access to the secondary containment is closed.

3. All secondary containment penetrations not capable of being closed by OPERABLE secondary containment automatic isolation dampers / valves and required to be closed auring accident conditions are closed by valves, blank flanges, or deactivated automatic dampers / valves secured in the closed position.

I c. At least once per 18 months:

1. Verifying that one standby gas treatment subsystem will draw down the secondary containment to greater than or equal to 0.25 inch of vacuum water gauge in less than or equal to 567 seconds at a flow rate not exceeding 3800 cfa, and

2. Operating one standby gas treatment subsystem for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and main-taining greater than or equal to 0.25 inch of vacuum water gauge in the secondary containment at a flow rate not exceeding 3000 cfm.

When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for drai,ning the reactor vessel.

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FERMI - UNIT 2 3/4 6-51 1

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NRC-89-0093, Application for Amend to License NPF-43,incorporating Change to Tech Specs 3/4.6.5.1 Re Secondary Containment Integrity & Definition 1.36

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